If you want a new way to control the damage that Tobacco products do to your community, then this may interest you.

This post offers credible tobacco industry data showing all of the pesticides that contaminate Tobacco products worldwide. It is published by CORESTA, the tobacco industry’s captive science & research institute. This information alone can empower local initiatives by offering credible evidence that banned toxic substances may be contaminating locally-sold Tobacco products.

If your local health department has regulations that allow it to investigate whether a product being sold in your community is contaminated with banned pesticide residues, then this list will give them probable cause to sample locally-sold Tobacco products and test for the presence of banned pesticide chemicals.

It is important for you to keep in mind, when making such a request, that (1) it doesn’t matter that the products are Tobacco – they are just like pesticide contaminated candles, air fresheners or incense – and (2) these contaminants are present because of negligence by the manufacturer and lack of regulatory oversight by any superior authority, so the local authorities have to act in the interest of public health and safety.

So this is it – the official (but highly confidential) June, 2018 tobacco industry guide to the pesticide chemicals used on tobacco worldwide. It’s an industry list cautioning manufacturers to ‘watch out’ for these chemicals that remain on Tobacco from the fields, which means that it’s a list of what the industry knows is potentially present in any Tobacco product anywhere.

Many of these pesticides are damaging to human health at very low levels of chronic exposure – just like a smoker gets 100-200 times a day, 365 days a year puffing away and inhaling the pesticide residues invisibly contaminating the tobacco in their cigarette. (Except that it isn’t really tobacco, but that’s another post.)

But the really severe public health threat created by pesticides on Tobacco lies in the industry’s attempt to pivot toward vaporizing. Imagine that instead of being at least partially destroyed by combustion and smoking, all those pesticides are now being gently vaporized and delivered full-strength to your lungs as IQOS Tobacco vapor.

While the tobacco industry publishes pesticide standards for its members, it makes clear that nobody actually has to follow this industry guidance. The tobacco companies are safe from accountability because there is no testing of commercial cigarettes in the United States for the presence of any of these chemicals, and what little testing the FDA, EPA and USDA do perform almost seems deliberately designed to shield the tobacco industry from investigation. It’s not as if the FDA doesn’t have the authority to demand that Tobacco companies at least keep the contamination down a little.

907(a)(1)(B) of Section 907 of the Federal Food, Drug, and Cosmetic Act:

(B) ADDITIONAL SPECIAL RULE.—Beginning 2 years after the date of enactment of the Family Smoking Prevention and Tobacco Control Act, a tobacco product manufacturer shall not use tobacco, including foreign grown tobacco, that contains a pesticide chemical residue that is at a level greater than is specified by any tolerance applicable under Federal law to domestically grown tobacco.

Please keep that language in mind as you browse the list below. Chronic low-dose exposure to any one of the pesticides on this list, just by itself, is enough to cause serious damage to human adults, children and babies. The US government, along with the health authorities of every state, seem collectively uninterested in knowing what dozens of these violent chemicals, all being either burned or heated, smoked or vaporized and then inhaled actively or passively are doing to smokers or vapers, their families and everybody else downwind every day of their lives.

One last thing – notice that there are a lot of banned pesticides on the list. That’s because the Tobacco industry recognizes that large stores of these chemicals still exist and farmers still use them for one simple reason – they kill bugs. It might also be that these chemicals are still being made in black factories in India and China.

Whether using banned pesticides or not, most small farmers in the Third World can’t even read the labels, if there are any, so all they care about is killing bugs and fungus. Every pound of tobacco that bugs eat and fungus destroys is one less pound the farmer has to sell to feed his family, which doesn’t mean that the kids just go without a snack for a day or two.

So of course hundreds of thousands of small tobacco farmers worldwide are going to use triple-witching stuff like Endrin, Heptachlor, Aldrin, and Dieldrin whenever they can get it or whenever they are told to use it. Because while manufacturing of these incredibly toxic chemicals is banned almost everywhere, ‘black’ factories in China and India are churning out the oldies but goodies by the ton and selling them in countries where 50% of all pesticides are used on just one crop – tobacco.

But of course regulatory authorities in the ‘advanced’ countries like the US don’t test for these banned pesticides in anything anymore, much less in tobacco products like cigarettes, because “nobody uses them anymore and all the old stores have been used up or destroyed long ago”.

Table 1. Crop Protection Agent (CPA) Guidance Residue Levels (GRL)

This is not a list of recommended CPAs (Crop Protection Agents) for tobacco. That is a matter for official and/or industry bodies in each country.

GRLs have not yet been set for all CPAs registered for tobacco. Setting GRLs is an ongoing process based on a list of priorities decided by frequency of use and importance to leaf production.

The presence of a compound does not imply endorsement by CORESTA

The entries in the list do not replace MRLs (Maximum Residue Levels) set by the authorities. Compliance with MRLs is a legal requirement for countries that have set them for

In countries where fungal diseases such as blue mould are a persistent problem in the field throughout the growing season, the use of dithio- carbamates (DTC) fungicides may be an essential part of the season-long disease management strategy and in keeping with GAP as a means of ensuring crop quality and economic viability for the producer. Under high disease pressure residues of dithio- carbamates (DTC) fungicides slightly in excess of the specified GRL may be observed. In countries where there is not a field fungal disease problem the use of fungicides is not necessary, and there should be no residues detected. Consistent with GAP, dithiocarbamates (DTC) fungicides must be used only according to label instructions to combat fungal diseases in the seedbed and in the field.

No.

CPA

GRL

(ppm)

Residue definition

Notes

47

Endosulfans (S)

1

sum of alpha- and beta-isomers and Endosulfan-sulphate expressed as Endosulfan

sum of Heptachlor and two Heptachlor epoxides (cis- and trans-) expressed as Heptachlor

62

Hexachlorobenzene

0.02

Hexachlorobenzene

63

Imidacloprid

5

Imidacloprid

64

Indoxacarb (S)

15

Sum of S isomer + R isomer

65

Iprodione (S)

0.5

sum of Iprodione and N-3,5- dichlorophenyl-3-isopropyl-2,4- dioxoimidazolyzin-1-carboxamide expressed as Iprodione

66

Malathion

0.5

Malathion

67

Maleic hydrazide

80

Maleic hydrazide (free and bounded form)

In some instances, where GAP is implemented and label recom- mendations with regard to application rates and timing are strictly adhered to, residue levels may exceed the current GRL of 80 ppm as a result of extreme weather conditions and the current technology available for application. However, as with all CPAs, all efforts should be made to strictly follow label application rates, and use should be no more than necessary to achieve the desired effect.

Carbendazim is the degradation product of Benomyl and Thiophanate-methyl. In the case the same sample contains residues of both Carbendazim and/or Benomyl/Thiophanate-methyl, the sum of the residues should not exceed 2

Deltamethrin is the degradation product of Tralomethrin. In the case the same sample contains residues of both Deltamethrin and Tralomethrin, the sum of the two residues should not exceed 1

Dichlorvos is the degradation product of Naled and In the case the same sample contains residues of both Dichlorvos and/or Naled/Trichlorfon, the sum of the residues should not exceed 0.1 ppm.

Omethoate is the degradation product of Dimethoate. In the case the same sample contains residues of both Dimethoate and Omethoate, the sum of the two residues should not exceed 0.5

The Dithiocarbamates Group includes the EBDCs: Mancozeb, Maneb, Metiram, Nabam and Zineb – as well as Amobam, Ferbam, Policarbamate, Propineb, Thiram and

Methomyl is the degradation product of Thiodicarb. In the case the same sample contains residues of both Methomyl and Thiodicarb, the sum of the two residues should not exceed 1

Fluopyram added to GRL list June

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What if every scientific study on cigarettes, smoking and health run by the tobacco industry and all of the “data” that has emerged over the past 50 years is severely compromised at the deepest levels?

What if most or all of the data the tobacco industry has been generating continuously to support its claims is fundamentally compromised by flawed research protocols and methodologies, contaminated research materials, inexplicable oversights, and good old-fashioned deceptive practices? What if all this can be directly linked to a single, underlying,’Achilles Heel’ flaw that can be easily verified?

What would that imply for regulations on tobacco products, for anti-tobacco legislation, for treaties and international agreements, for health care and insurance policies, for victims and juries, and for generations of legal decisions and precedent – if all were based on flawed science?

It is.

The core assumption of virtually all smoking & health research is that it is studying tobacco and only tobacco.

A corollary assumption is that cigarettes are tobacco and that cigarette smoke is tobacco smoke.

So when cigarette smoke is generated for research purposes, the assumption is that the smoke being studied is tobacco smoke or, if that assumption is ever questioned, its functional equivalent.

It’s not.

Virtually every research study on smoking and health run by the tobacco industry and its worldwide network of scientists and doctors since the 1970’s is based on the use of University of Kentucky standard “Reference Cigarettes”. Most or possibly all of the data derived using these standard Reference Cigarettes, which are used worldwide in virtually all tobacco industry studies involving cigarettes, are compromised and must be re-evaluated.

There are four main reasons why I believe that tobacco industry standard Reference Cigarettes consistently produce false and misleading data.

There is non-random selection bias in the commercially-sourced leaf tobacco components of Reference Cigarettes.

Explanation

The tobacco leaf used in production of Reference Cigarettes is “commercially-sourced”, and is a non-random sample of the commercially tobacco types available at the time of the manufacturing run. Reference cigarette manufacturers, working to published industry standards, simply use whatever Flue-Cured, Burley, Maryland and Oriental tobacco leaf is convenient for a particular run of Reference Cigarettes. (It’s unclear whether there is more than one manufacturer for a run of reference cigarettes.) The Flue-Cured, for example, could be from North Carolina or Brazil or Zimbabwe. As long as it’s “Flue-Cured”, it meets tobacco industry scientific research standards and no other selection standards or procedures are specified by the certifying body for the tobacco industry. This means there is significant potential variability between the “Flue-Cured” selected for manufacturing into a run of Reference Cigarettes and the Flue-Cured that another manufacturer might use in their cigarette production. The same is true for all tobacco types selected and used in Reference Cigarettes.

There is uncontrolled and unacknowledged variability in the “sheet tobacco” components of Reference Cigarettes.

Explanation

Tobacco Sheet is manufactured from tobacco waste, stems and scrap of variable, multiple, indeterminate foreign and domestic origins, and includes non-tobacco constituents that also vary depending on the “sheet” or “recon” tobacco manufacturing process used. Tobacco sheet is a 20-25% component of Reference Cigarettes. Millions of pounds of foreign-sourced tobacco waste is imported into the US annually for the specific purpose of “tobacco sheet” manufacturing by multiple manufacturers in multiple factories using multiple processing methods. Yet the industry standards for Reference Cigarette manufacturing don’t acknowledge this critical source of variability in the components of Reference Cigarettes, the reference standard for all industry-sponsored cigarette testing worldwide. The highly variable nature of a 20-25% component of all Reference Cigarettes seems sufficient in itself to invalidate data based on the use of Reference Cigarettes. Further, some of the Reference Cigarette recon is standard recon and some is “Sweitzer method” recon, and the two processes are not equivalent.

Finally, there’s variation in tobacco itself. “Tobacco is not a homogeneous product. The flavor, mildness, texture, tar, nicotine, and sugar content vary considerably across varieties or types of tobacco. Defining characteristics of different tobacco types include the curing process (flue-, air-, sun-cured) and leaf color (light or dark), size, and thickness. A given type of tobacco has a different quality depending on where it is grown, its position on the stalk (leaves near the bottom of the stalk are lower in quality), and weather conditions during growing and curing.” (from Tobacco and the Economy , USDA)

There are known but not included in analysis, highly variable concentrations of agrichemical and pesticide residues on the leaf tobacco component and in the sheet tobacco component of Reference Cigarettes.

Explanation

Tobacco leaf, sheet, waste and scrap all carry a burden of biologically active pesticides that are not on the industry list of “toxicants” tested for in standardizing the Reference Cigarettes. Extensive research literature establishes the widespread presence of pesticide residues on commercially-sourced tobacco and tobacco waste. When testing is performed on cigarette smoke using the Reference Cigarettes as a baseline or standard, the measured smoke stream constituents will be the byproducts of the interaction of recognized, known and acknowledged tobacco constituents along with an undetermined number and concentration of unknown pesticides whose common presence on commercial, and especially on imported tobacco is well-established. There is no way to tell how the measured ‘toxicants’ in any sets of results using Reference Cigarettes have been affected by combustion of pesticide residues because the tobacco being used is not tested for the presence or concentration of those residues. Because of this error in research design, any smoke stream ‘toxicant’ data based on Reference Cigarettes will be flawed in unpredictable ways and should not be accepted without re-evaluation.

The tobacco leaf used for manufacturing Reference Cigarettes is sourced from standard unsegregated commercial markets for Flue-Cured, Maryland, Oriental, and Burley tobacco leaf.

Explanation

Commercially sourced tobacco is, unless otherwise specified, an aggregated universe of tobacco leaf grown and handled under a wide range of environmental and agronomic conditions. Only tobacco leaf grown domestically under controlled conditions and kept separate from commercial tobacco could be used as to produce a reference cigarette that would be uniform enough in biochemical makeup to legitimately serve as a universal standard. A large proportion of the Flue-Cured and Maryland, and nearly all the Oriental Tobacco in the commercial market at any given time is from foreign sources. This means that the Reference Cigarette manufacturers who simply source by category have no idea where any given batch of leaf comes from or what its biological parameters might be aside from any commercial sampling or batch testing testing they may or may not do. As a result there simply can’t be uniformity or standardization of important parameters of the biological makeup of the tobacco plant materials used in manufacturing Reference Cigarettes.

So that’s it. Well, actually there a whole lot more, supported by reams of references all from peer-reviewed sources. But for now I thought I would just lay this out as clearly and simply as possible and see if anyone cares that the tobacco industry has been creating fake science for 50 years now and they have never really been called on it much less held accountable in meaningful ways.

The “Tobacco Settlement”, for example, is a horrible joke and a legal travesty but it is based on what can be shown to be such deliberately bad science and deceptively derived evidence that the whole issue of liability and intent on the part of the Tobacco industry should be open to re-litigation and to criminal prosecution as well.

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